Metal classification under sales tax notifications excludes manufactured aluminium rolled products and extrusions from concessional treatment.

U.P. sales tax notifications referring to "metal" were construed by their scheme and structure to cover the primary, original saleable form of the metal, not later fabricated forms emerging after processing. Aluminium ingots and billets were treated as primary commodities, but rolled products and extrusions were regarded as distinct commercial commodities produced by manufacture. The wider wording in the later notification, including "all kinds of minerals, ores, metals and alloys," did not alter that classification scheme. The result is that aluminium rolled products and extrusions fall outside the concessional entry for metals and alloys.

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Issues: Whether aluminium rolled products and extrusions are covered by the term "metal" in the relevant U.P. Sales Tax notifications, so as to be taxed at the concessional rate applicable to metals and alloys.

Analysis: The notifications were construed by their scheme and structure. The term "metal" was held to refer to the primary or original saleable form of the metal, not to later fabricated forms that emerge after processing. The arrangement of earlier notifications, which separately mentioned metal and its processed forms, supported this contextual reading. Aluminium ingots and billets were treated as primary commodities, while rolled products and extrusions were regarded as distinct marketable commercial commodities produced by manufacture. The wider meaning of "including" in the later notification and the broad language "all kinds of minerals, ores, metals and alloys" did not alter that scheme. Authorities on common parlance and product identity did not assist the assessee because the issue turned on the intended classification in the notifications.

Conclusion: Aluminium rolled products and extrusions are not "metal" for the purposes of the notifications and are distinct commercial commodities outside the concessional entry.

Ratio Decidendi: For sales tax notifications, a reference to a metal in its marketable primary form does not extend to fabricated products that have become distinct commercial commodities through manufacture.

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